Supreme Court Rules: When Law Requires a Specific Manner, It Must Be Followed Exactly – Emphasizing Strict Adherence to Legal Procedures.

Introduction

The Supreme Court of India has once again reaffirmed the well-established principle of strict adherence to legal procedures, stating that when the law prescribes a specific method for performing an act, it must be followed precisely. In a case concerning the management dispute of Shri Khereshwar Mahadev Va Dauji Maharaj Samiti, Aligarh, the Court ruled that any deviation from the legally mandated process renders actions invalid.

Supreme Court of India – Upholding Justice with Strict Adherence to Legal Procedures

Background of the Case

The dispute revolved around the management of Shri Khereshwar Mahadev Va Dauji Maharaj Samiti in Aligarh, with different committees claiming control over the temple. Over the years, the litigation history of this case involved multiple suits and appeals.

The appellant, responsible for managing the temple, initially filed a suit before the Additional Civil Judge, Senior Division, Aligarh. However, the appellant’s request for a temporary injunction was rejected. Upon appeal, the Additional District Judge allowed the appeal and directed both parties to maintain the status quo.

Meanwhile, Respondent No.5, Manju Devi, the Pradhan of Gram Sabha, Hardaspur, filed an application before the District Magistrate to implement an earlier order directing that the temple be handed over to the Gaon Sabha, Hardaspur. Since the District Magistrate did not act on her request, Manju Devi filed a writ petition before the Allahabad High Court. The High Court ruled in her favor, directing the authorities to transfer possession of the temple to the respondents.

The appellant, arguing that the High Court issued its order without granting them an opportunity of hearing, challenged the decision by filing a Special Leave Petition before the Supreme Court.

Observations of the Supreme Court

Supreme Court’s Emphasis on Strict Adherence to Legal Procedures

A key theme of the Supreme Court's ruling was the reaffirmation of the doctrine that when the law mandates a particular procedure, it must be followed strictly. The Court emphasized that legal formalities cannot be overlooked or bypassed under any circumstances.

In this case, the Court noted that any legal proceeding involving the Gram Sabha must be initiated through a formal resolution passed by the Gram Sabha itself. However, the writ petition before the High Court was filed solely by Manju Devi, the Pradhan of Gram Sabha, Hardaspur, without any such resolution. This procedural lapse rendered the petition legally untenable.

Criticism of the High Court’s Approach

The Supreme Court criticized the High Court’s handling of the case, highlighting that:

• The Additional District Judge, Aligarh, had earlier directed both parties to maintain the status quo regarding the temple’s possession, a crucial order affecting the rights of both parties.

• The High Court disregarded this order and proceeded to transfer possession of the temple despite the ongoing civil dispute.

• The Tehsildar/SDM’s report clearly stated that no further proceedings could be undertaken as the civil suit regarding the temple was still pending. This report was a significant piece of evidence that the High Court failed to consider, demonstrating judicial oversight.

Thus, the Supreme Court reinforced the principle that when the law mandates a specific manner for performing an act, it must be strictly followed, without deviation.

Referred Judgments

The Supreme Court relied on several precedents to support its ruling:

1. State of Uttar Pradesh v. Singhara Singh & Ors. (1964 AIR 358)

The Court held that if a statute prescribes a specific method for performing an act, that method alone must be followed, and no other alternative is permissible. This case is frequently cited to reinforce the necessity of adhering to statutory procedures.

2. Nazir Ahmad v. King Emperor (1936 AIR 253, Privy Council)

The Privy Council ruled that when a law prescribes a particular procedure, strict adherence to that procedure is required, and any other approach is invalid. This case set a precedent for ensuring procedural compliance.

3. Dhananjaya Reddy v. State of Karnataka (2001) 4 SCC 9

The Court ruled that failure to follow the prescribed legal procedure renders the proceedings invalid. This judgment reinforces that non-compliance with legal mandates cannot be excused.

Case Details

• Case Name: Shri Khereshwar Mahadev Va Dauji Maharaj Samiti, Aligarh v. The State of Uttar Pradesh & Ors.

• Case Number: SLP(CRL) Nos.13258-13259/2024

• Court: Supreme Court of India

• Judgment Date: 2024

Conclusion

The Supreme Court's ruling in Shri Khereshwar Mahadev Va Dauji Maharaj Samiti, Aligarh v. The State of Uttar Pradesh & Ors. (SLP(CRL) NOS.13258-13259/2024) underscores the fundamental legal principle that when a law specifies a particular method for accomplishing something, it must be adhered to strictly. Any deviation from the prescribed procedure results in legal invalidity. This decision serves as an important reminder of the necessity for courts and authorities to ensure that all legal formalities are followed precisely.

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